My Cold Leads
ES
My Cold Leads

Privacy Policy

Last updated: June 2026

1. Interpretation and Definitions

1.1 Interpretation

Capitalized words herein have specific meanings as described below, whether they appear in singular or plural form.

1.2 Definitions

  • Account: A unique profile created to access parts of our Service.
  • Affiliate: A company under shared control or ownership.
  • Company: Jack Kelly, Calle San Fernando, 40. Referred to as "We," "Us," or "Our."
  • Cookies: Small data files stored on your device to track website interactions.
  • Country: Spain
  • Device: Any technology used to access the service (e.g., smartphone, computer).
  • Personal Data: Information identifying an individual.
  • Service: The My Cold Leads website (https://mycoldleads.com).
  • Service Provider: Third-party entities processing data on behalf of the Company.
  • Usage Data: Technical information automatically collected during Service use (e.g., IP address, browser type).
  • You: Individuals or entities using the Service.

2. Collecting and Using Your Personal Data

2.1 Types of Data Collected

Personal Data

We may collect: Email Address, First and Last Names, Usage Data.

Usage Data

Includes IP address, browser type/version, time on pages, and diagnostic data. Collected automatically for system optimization and security.

2.2 Tracking Technologies

We use tools like cookies and web beacons to analyze activity and enhance usability. Session cookies expire once you leave; persistent cookies remain until manually deleted. You may remove and disable cookies at any time via your web browser.

2.3 Use of Data

We use collected data to:

  • Maintain and improve the service
  • Manage user accounts, contract compliance, and communications
  • Provide tailored news and offers, unless opted out
  • Analyze data to enhance user experience and address support requests

2.4 Data Sharing

We share your data:

  • With service providers for analytics or operational needs
  • For business transfers, like mergers/acquisitions
  • With affiliates and partners, ensuring compliance with privacy terms
  • When legally required or with explicit consent

2.5 B2B Outreach Communications

Separately from our website services, we send business introductions by email to professionals whose work contact details we obtain from public B2B sources, professional networks (e.g. LinkedIn), and licensed B2B databases (e.g. Apollo). Our legal basis is legitimate interest under GDPR Article 6(1)(f) for B2B commercial outreach. We process the recipient's name, work email, job title, and employer. Data is retained while the contact is active in our outreach lists and is deleted on opt-out or after 24 months of no engagement. Processors include Smartlead (email delivery, US/EU), Supabase (database, EU), and Apollo (data source, US). You have the right to access, rectify, erase, restrict, port, and object to processing, and to lodge a complaint with the Spanish Data Protection Authority (Agencia Española de Protección de Datos, www.aepd.es). To exercise any right or opt out of further communications, reply STOP to any email or write to info@mycoldleads.com.

2.6 Lead Data Processed on Behalf of Clients

When we run advertising and lead-generation campaigns for our clients - including LinkedIn Lead Gen Form campaigns - we collect the contact details that individuals submit through those forms (such as name, work email, job title, employer, and any other fields the form requests). For this lead data, our client is the data controller and we act as a data processor on their behalf under a data processing agreement. We retrieve these leads via the LinkedIn Lead Sync API and deliver them into the client's own CRM or marketing-automation system so the client can follow up. We process this lead data solely to provide the service to that client; we do not use it for our own purposes, sell it, or share it with anyone other than the client who owns it. To exercise your data rights in relation to a lead you submitted through a campaign, contact the client running that campaign, or contact us at info@mycoldleads.com and we will forward your request to the relevant controller.

2.7 International Data Transfers

Some of our service providers are located outside the European Economic Area (EEA), including in the United States (e.g. Smartlead, Apollo). Where we transfer personal data outside the EEA, we rely on appropriate safeguards under Chapter V of the GDPR - primarily the European Commission's Standard Contractual Clauses - so that your data receives an equivalent level of protection. You may request a copy of the relevant safeguards by contacting info@mycoldleads.com.

3. Retention of Your Personal Data

We retain data only as long as needed for outlined purposes, or to comply with legal obligations. Usage data is generally kept shorter unless needed to ensure system security.

4. Your Rights

You can update, access, or delete data by contacting us. We may retain certain data if legally obligated.

5. Legal Disclosures

Data may be disclosed:

  • During mergers or litigation
  • To comply with legal obligations or enforce company rights
  • To handle misuse, fraud, or threats to safety

6. Security

We employ security measures to protect data but cannot guarantee 100% protection from breaches.

7. Children's Privacy

We do not knowingly collect data from individuals under 18. We encourage parents without prior consent to request data deletion for minors.

8. External Links

We are not responsible for external sites accessed via links within our Service. Please review their privacy terms independently.

9. Changes to this Policy

We may update this Privacy Policy over time. Updates will be published on this page, and significant changes will be communicated via email or on our platform.

Contact Us

For concerns about this Privacy Policy, reach us at:

Email: jack@mycoldleads.com